Tech.(I) Pvt. Ltd. -vs- DCIT, Circle-2(2), Kolkata
(formerly Anshin Software Pvt. Ltd.)
[PAN: AADCA 8967 A]
(Appellant) (Respondent ... Kolkata -vs- Nomura Research Institute Financial Tech.(I) Pvt. Ltd.
(formerly Anshin Software Pvt. Ltd.)
[PAN: AADCA 8967 A]
(Appellant) (Respondent)
For the Appellant : Shri
Services (TRS). MCS
division apart from management consultancy services caters to the software solutions of
various clients. FAS provides business advisory services on corporate finance ... Salt Lake City, Kolkata - 700091 for setting up of a computer
software (expansion) project. The Eligibility Certificate for Incentives under W.B.
Incentive Scheme
rubber products, Contract Manufacturing (Toll Manufacturing) - tolls, Cellular Mobile services, Consultancy services. Software Development services - Client server and internet software solutions, Software development services - Design ... engineering software (CAD/CAE), engineering software etc.) Software development services - Embedded systems and communication software. Software development services - General, Engineering and construction services (Dams, bridge
field before the Panel shows that the assessee company have
received hardware/software from third parties directly and the biling was also ... usage of financial reporting and
Finance and treasury group record management software and databases;
- Treasury management strategy and guidance; and
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ITA No.2489
manufacturing and
distribution of electric meters and related components. It also renders software
development services to its group companies. In the course of its business ... depicted below:-
Landis + Gyr
Manufacturing segment Trading segment-Meters Service segment
Meters Software development
Transaction
Domestic Export Business Import of Finished Goods
Business Transactions
Export
bundled set of information technology based
services (including but not limited to software development (SD) services, business
process outsourcing (BPO) services etc.);
(b) That ... crores as applied by the Ld. TPO.
(c) Rejecting Akshay Software Technologies Ltd. as a comparable company in spite of
having Related Party Transaction
thereby
violating section 144C(13) the Act by:
a. not including Akshay Software Technologies Ltd. in the final set of
comparables
b. not excluding interest ... income in the cases Kuliza Technologies Pvt. Ltd. and
Inteq Software Ltd.
2. For that the Assessing Officer erred in assessing the total income
justified in treating the software expenses of Rs. 39,58,659/- [55,16,940 - 15,58,281]
as revenue expenditure ignoring that the said expenses ... assessee and also without ascertaining the nature / utility of the software, it is simply not
possible for the Assessing Officer to ascertain whether software were
customer would presumably not tend to
believe that the offshore IT/software development services under Global Delivery Model is being
rendered ... enter into contract with either the assessee or the
subsidiaries for providing software development services. The contracts entered with customers also
mention the expected standard
deleting the addition of Rs. 24,25,168/- being
transaction with EDP Software Ltd. ignoring the fact that the assessee is
holding all the shares ... with respect to advance received from EDP Software
Ltd.
The basic grounds of additions by the Assessing Officer were that fresh advances
have been given
